City of Westminster v. Dogan Construction Co.

The majority holds that notes prepared by City agents on questionnaire forms completed pursuant to telephone interviews with the references of a bidding contractor constitute “letters of reference concerning employment” exempt from public access as required by the Colorado Open Records Act (Act), and that therefore, Dogan Construction Co. (Dogan) has no right to inspect them. Maj. op. at 593. Because I disagree with the majority’s expansive interpretation of the phrase, “letters of reference concerning employment,” under the Act, I respectfully dissent.

I

In discerning the meaning of a statute,…